SEC Comment Letter for INTERNATIONAL BUSINESS MACHINES CORP (IBM) (CIK 0000051143) (IBM) — Oct 25, 2022

INTERNATIONAL BUSINESS MACHINES CORP (IBM) (CIK 0000051143)
Date: Oct. 25, 2022 · CIK: 0000051143 · Accession: 0000000000-22-011682

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AI Filing Summary & Sentiment

File numbers found in text: 001-02360

Date

October 25, 2022

Author

Not clearly detected

Form

UPLOAD

Company

INTERNATIONAL BUSINESS MACHINES CORP (IBM) (CIK 0000051143)

Letter

United States securities and exchange commission logo October 25, 2022 Frank P. Sedlarcik Vice President, Assistant General Counsel and Secretary International Business Machines Corporation One New Orchard Road Armonk, New York 10504 Re:International Business Machines Corporation Definitive Proxy Statement on Schedule 14A Filed March 7, 2022 File No. 001-02360 Dear Frank P. Sedlarcik: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Disclosure Review Program

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United States securities and exchange commission logo
October 25, 2022
Frank P. Sedlarcik
Vice President, Assistant General Counsel and Secretary
International Business Machines Corporation
One New Orchard Road
Armonk, New York 10504
Re:International Business Machines Corporation
Definitive Proxy Statement on Schedule 14A
Filed March 7, 2022
File No. 001-02360
Dear Frank P. Sedlarcik:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Disclosure Review Program

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